# Connecticut RUBS Ban: How Apartment Owners Switch to Submetering

Source: https://submeter.com/connecticut-rubs-ban/
Publisher: National Exemption Service (NES), https://submeter.com. Last reviewed September 2026.

RUBS is out in Connecticut. Here is how apartment owners switch to PURA-approved water submetering: the law, the approval steps, fees and timing.

## Is RUBS legal in Connecticut?
No. In Northland Investment Corp. v. PURA (2024), the Connecticut Supreme Court held that ratio utility billing breaks Conn. Gen. Stat. 16-262e(c), which makes the owner liable for utilities unless a unit is individually metered or billed for its own use. Public Act 26-113 then made any lease clause charging a resident for utilities without a separate meter for their unit unenforceable, for leases signed or renewed on or after October 1, 2026. Owners have two main ways to recover the cost: build an estimate into the rent, or meter each unit. Water submetering is allowed with PURA approval. Electric submetering is limited to certain buildings, and gas submetering is not allowed.

Some Connecticut owners have split the master water bill by formula, using occupants or square footage, and added each share to the rent statement. The Supreme Court said in 2024 that state law doesn't allow it. In 2026 the legislature wrote a similar rule into lease law, one that requires a separate meter, so each lease that renews now loses its RUBS clause.
This guide covers what changed, what is still allowed, how PURA approval works, and how to move a property from RUBS to metered billing without losing a year of recovery. It's written for owners and managers with 80 units or more. At that size the water bill is big enough for the choice to matter.
## Connecticut RUBS law: Northland and Public Act 26-113
### 2024: the Supreme Court rules on Northland
Connecticut law makes the owner of a residential building liable for the electricity, gas, water and heating fuel furnished to it, with one exception: service furnished to a unit [on an individually metered or billed basis](https://www.cga.ct.gov/current/pub/chap_283.htm) for that unit's exclusive use. That is section 16-262e(c).
Northland Investment Corporation owns apartment buildings in Hartford and Enfield. It asked PURA to confirm it could bill tenants a formula share of the gas, water and sewer bills, based on square footage, occupants and bedrooms. PURA said no, and the [Connecticut Supreme Court agreed on May 7, 2024](https://www.jud.ct.gov/legalresources/Docs/LJDocs/Misc/2024/19/CLJ05072024.pdf). A formula share isn't service billed to a unit for its own exclusive use, so the owner stays liable for the bill. The court pointed out that the law was meant to make owners pay when a building has one master meter rather than individual meters or submeters for each unit. Three of the justices dissented.
### 2026: the legislature writes it into lease law
[Public Act 26-113](https://www.cga.ct.gov/2026/ACT/PA/PDF/2026PA-00113-R00SB-00335-PA.PDF), signed June 4, 2026, added a new item to the list of things a Connecticut lease cannot require. A tenant cannot be made to pay for utilities billed to them if no separate meter measures the utilities delivered only to their unit. A clause that does is unenforceable.
It took effect October 1, 2026 and applies to rental agreements entered into or renewed on or after that date. On a portfolio with one-year leases, that means the whole rent roll falls under it by about October 2027, one renewal at a time.
| Utility | RUBS | Submetering |
| --- | --- | --- |
| Water and sewer | Not allowed | Allowed, with PURA approval before billing |
| Electric | Not allowed | Only campgrounds, marinas, buildings powered by Class I renewables or combined heat and power, or other sites PURA approves (16-19ff) |
| Natural gas | Not allowed | Not allowed |
A Connecticut law firm, [Pullman & Comley](https://www.pullcom.com/newsroom-publications-Connecticut-Landlords-Beware-RUB-Billing-Illegal-Multiunit-Properties), reported in 2025 that PURA has applied the Northland reasoning to commercial properties as well, a reading the firm said could be challenged. If you own mixed-use buildings, have counsel look at the commercial leases too.

## Options for Connecticut landlords after the RUBS ban
Keeping RUBS is off the list. That leaves three ways to handle utilities on a master-metered Connecticut property.
| Option | How it works | What to watch |
| --- | --- | --- |
| Build utilities into rent | Estimate the year's utility cost and fold it into a fixed monthly rent. The court and PURA both said this is allowed. | The owner carries every rate increase and every leak until the next renewal. Residents have no reason to use less. Advertised rent goes up by the estimate. |
| Submeter water, with PURA approval | A meter on each unit's water line. Residents pay for what their unit measures. | Needs PURA approval before the first bill, and a plumbing survey. Older buildings with several lines per unit need more than one meter. |
| Utility-owned meters per unit | The utility bills each resident directly. | Only works if the water utility will set and read its own meter at each unit. Ask the utility what your building would need. |
For most properties over 80 units, the choice comes down to building water into rent or submetering it. Here's how the two compare in dollars.

## Utilities included in rent vs water submetering: the cost
Take a 200-unit master-metered property paying $60 per unit per month for water and sewer, $144,000 a year. Your own bill is the one to use, and the [utility expense recovery calculator](https://submeter.com/utility-expense-recovery/) will run it.
### If you build it into rent
The owner sets a fixed amount per unit at signing. If the bill comes in higher, the owner pays the difference until each lease renews. [Bluefield Research found](https://www.wateronline.com/doc/national-water-and-sewer-bills-rise-outpacing-inflation-as-utilities-face-rising-cost-pressures-0001) household water and sewer bills across 50 US cities rose 5.1% in 2025. On $144,000, a 5.1% increase is $7,344 the property absorbs before rents can catch up.
The bigger cost is usage. A resident on a fixed rent has no reason to take shorter showers or report a running toilet. Every gallon is still on the owner's bill.
### If you submeter
Residents pay for what their own unit uses, and they use less. In the 2004 national submetering study funded by the EPA, the National Apartment Association and the National Multi Housing Council, submetered properties used [15.3% less water](https://www.ebmud.com/water/conservation-and-rebates/water-conservation-publications/multi-family-submetering-billing-allocation-study) than comparable properties where the owner paid. On a $144,000 bill, that's up to about $22,000 a year, less the fixed charges that don't change with use.
At one 337-unit NES community where meters went in as leases renewed, the submetered units used 34% less water than the units still waiting for meters, and their average bill was $54.22 against $84.72. At two other NES properties, the owner's own water and sewer cost fell 95% and 99% after submetering. More on those on the [results and case studies](https://submeter.com/results-case-studies/) page.
| Question | Built into rent | Water submeters |
| --- | --- | --- |
| Who pays for a rate increase | Owner, until renewal | Residents, from the next bill |
| Who pays for a leak inside a unit | Owner | The resident sees it on their bill, and daily reads flag it |
| Effect on water use | None expected | 15.3% less in the national study |
| Upfront cost | None | Meters and install, phased with renewals |
| Advertised rent | Higher by the utility estimate | Unchanged; water billed separately |
| Holds up under Public Act 26-113 | Yes | Very likely, with a meter for each unit and PURA approval (not yet tested in court) |

## Submetering older Connecticut apartment buildings
A lot of Connecticut's rental housing is old. Census figures for 2020 to 2024 show half of Hartford's rental housing was built in 1956 or earlier, and half of New Haven's in 1957 or earlier. Stamford's is newer, with a median of 1984. NES has local pages for [Hartford](https://submeter.com/submetering-apartments-in-hartford/), [New Haven](https://submeter.com/submetering-apartments-in-new-haven/) and [Stamford](https://submeter.com/submetering-apartments-in-stamford/).
Age matters because a submeter measures one water line. A garden building with one line into each unit takes one meter per unit. An older building with a kitchen riser and a bathroom riser takes two, and some take more. That changes the install cost, and in some buildings it changes whether meters make sense. NES surveys the plumbing at every property before quoting, so the number you get is the number for that building.
| City | Renter households | In buildings with 20+ units | Median year rental housing built |
| --- | --- | --- | --- |
| Hartford | 36,400 (74%) | 10,800 | 1956 |
| New Haven | 39,200 (72%) | 12,000 | 1957 |
| Stamford | 28,300 (51%) | 15,800 | 1984 |

## How to get PURA approval for water submetering
Water submetering in Connecticut needs state approval. A regulation dating to 1966, [Conn. Agencies Regs. 16-11-55](https://eregulations.ct.gov/eRegsPortal/Browse/RCSA/Title_16Subtitle_16-11Section_16-11-55/), allows it only with the commission's approval, and PURA is that commission now. [PURA's own FAQ](https://portal.ct.gov/pura/consumer-services/frequently-asked-questions) says approval is for a specific location and runs as a formal legal proceeding, a docket, that anyone can look up.
Owners file these regularly. [PURA's list of 2023 final decisions](https://portal.ct.gov/-/media/PURA/2023-Annual-Report---Appendix-2-Final-Decisions-List.pdf) includes six water submetering applications, for properties in Stamford, Greenwich, Canton, Seymour and Haddam, plus several electric ones.
### What a water approval looks like
A 2021 PURA decision for a residential property at 201 Commons Park Road South in Stamford ([Docket 12-03-06](https://portal.ct.gov/-/media/PURA/Docket-No-12-03-06-Final-Decision.pdf)) shows what PURA checks and what it expects afterward. PURA found the owner had the technical, financial and managerial capability to submeter water. It approved a new billing vendor and let the monthly service fee go from $3.25 to $3.50, which it called in line with its past decisions.
The approval came with standing orders. The owner must:
- Follow the state rules water companies follow on bill format, correcting bills for meter errors, keeping complaint records and testing meters.
- Never shut off a resident's water, for any reason.
- Submit any change to billing or customer service, including a new vendor or a fee change, for PURA approval at least 10 business days before it takes effect.
- Tell residents within 30 days when the water utility changes its rates.
### Who else weighs in
The Office of Consumer Counsel, the state's advocate for utility customers, can weigh in on these dockets. [Its published view](https://portal.ct.gov/-/media/OCC/WebBlurb041912pdf.pdf) is that water submetering should be approved only when it helps residents, or at least does no harm, and when the owner gives residents the same protections a water company would, like accurate meters and customer service.
In a 2011 case at a 97-home mobile home park, it argued a $9.61 monthly charge was out of line. It noted several other approved plans charged $3, and it faulted the plan for reading meters on site rather than remotely.
### Electric has a written timeline
For buildings that qualify under 16-19ff, PURA posts [step-by-step instructions](https://portal.ct.gov/-/media/PURA/electric/ElectricSubmeteringInstructionspdf.pdf) for electric submetering. They lay out how PURA handles electric applications.
1. File the application. Copies go to PURA, the Office of Consumer Counsel and the electric utility, Eversource or United Illuminating. PURA opens a docket.
2. Completeness review. Within 30 days PURA says whether the application is complete or needs more.
3. Notify residents. In an occupied building, the owner notifies residents within 10 calendar days of getting the docket number. Residents then have 30 days to send comments, and no hearing is held before that.
4. Decision. PURA tries to decide within 60 days of a complete application. Silence is never an automatic approval.
Two more points from those instructions are worth knowing if you buy and sell. Meters installed before approval are at the owner's own risk. And an electric approval belongs to the applicant, not the building, so a buyer has to apply again after closing. PURA publishes no timeline for water, so file well ahead of the lease renewals you want to bill.

## How to switch from RUBS to submetering, step by step
This is the order NES works in for a Connecticut property, so recovery keeps going where the law allows it and no stretch goes unbilled.
1. Check every lease form. Find the RUBS or utility clause in each lease template in use. From October 1, 2026, any new or renewed lease that still carries it has an unenforceable clause. Have Connecticut counsel review what goes in its place.
2. Survey the plumbing. NES walks the property, counts water lines per unit, and checks access. This sets the meter count and the install cost.
3. File with PURA. Water submeters need PURA approval before the first bill. NES prepares and files the application while the install plan is being finished.
4. Decide what renewing leases say in the meantime. Units that renew before their meter is billing still need lawful lease terms. One option is to build an estimate into rent for that stretch, then move to metered billing at the next renewal.
5. Install in phases, bill after approval. Meters go in building by building, and billing starts once PURA approves. The 337-unit NES community above did it as leases renewed, which kept the change in step with the lease cycle.
6. Tell residents first. A notice, a sample bill and a number to call that a real person answers, in English or Spanish. Residents who understand the bill dispute it less.
Running RUBS on a Connecticut property?. Send the unit count and 12 months of master-meter bills. A specialist replies within one business day with what the move to submetering would cost and recover.

## Connecticut submetering services from NES
NES handles all of it with its own staff, from the PURA filing to the resident who calls with a question about their bill.
- PURA filing and compliance. NES's in-house [compliance team](https://submeter.com/compliance-management/) prepares the water submetering application, answers PURA and Consumer Counsel questions, and keeps the property inside the approval afterward: rate-change notices to residents, the required bill format and meter test records.
- Plumbing survey and meter install. NES W-2 technicians survey every building, count the water lines per unit, and install the meters in phases that follow your lease renewals.
- Daily reads and leak alerts. Meters report every day to [MyReads](https://submeter.com/myreads-leak-detection/), so a running toilet or a leak inside a unit shows up in days, not on the next water bill.
- Resident billing. NES [bills residents](https://submeter.com/apartment-utility-billing/) for what their unit used, plus the service fee PURA approved, on the bill format PURA requires. Common-area water stays off resident bills.
- Resident support in English and Spanish. Residents call NES, not your leasing office, with questions about their bill. NES keeps the complaint records PURA requires.
- Repairs and replacements. When a meter or transmitter fails, NES [repairs or replaces it](https://submeter.com/submeter-repair-and-replacement/) so the unit keeps billing on a real reading. That matters in Connecticut, where the state meter rules let a resident ask for a meter test, and a meter found running more than 2% fast means a bill adjustment.
- Collections and reporting. Monthly recovery reporting by property, and [collections](https://submeter.com/collections/) on balances residents leave behind.
Already submetered in Connecticut with another company? NES can often keep the existing meters, adding nonproprietary transmitters where the old radios only talk to one vendor, and files the vendor change with PURA, which PURA required at a Stamford property in 2021. There is no long-term contract lock-in.

## Connecticut submetering billing rules: fees, shutoffs and common areas
- Common areas stay with the owner. NES never bills residents for hallways, laundry, irrigation, pools or other shared use. For electric, 16-19ff bans it outright.
- No markup on electric. Where electric submetering is allowed, the rate can be no higher than the utility charges that customer class ([16-19ff](https://www.cga.ct.gov/current/pub/chap_277.htm)). The same section tells PURA to cap a resident's cost at what the owner paid for that energy.
- No water shutoffs. In the Stamford approval above, PURA barred the owner from shutting off a resident's water for any reason. Plan on the same condition.
- Gas stays on the master meter. Gas submetering is not allowed in Connecticut, so gas cost is recovered through rent if at all.
- Fees. No statute sets a water service fee. PURA approves it docket by docket, $3.50 a month at the Stamford property above, and any change goes back to PURA. On electric, 16-19ff caps the rate at the utility's own rate and the energy cost at what the owner paid, so don't plan on adding a separate fee.
Connecticut's rules changed twice in two years, so have counsel review your lease language before it goes out.

## Advertising rent with utilities in Connecticut: Public Act 25-44
A 2025 law changed how Connecticut rent is advertised. Since October 1, 2025, [Public Act 25-44](https://www.cga.ct.gov/2025/ACT/PA/PDF/2025PA-00044-R00SB-00003-PA.PDF) requires the advertised rent to include every fee, charge or cost the tenant pays on a periodic basis. A landlord who breaks the rule owes the tenant one month's rent, and the court can add the tenant's attorney fees.
- Utilities built into rent. They are part of the rent, so the full amount goes in the listing.
- What the act leaves out of advertised rent. Utilities submetered under 16-19ff (the electric submetering law), and utilities the tenant pays straight to a utility company that vary from month to month.
- Submetered water. The act does not mention water submetered under PURA's water rules. Ask counsel how to show a submetered water bill, and any monthly billing fee, in your listings.
- Lease paperwork. Since April 1, 2026, a written lease must start with the state's rental terms summary form, and tenant payments go to rent first, then to other charges.

## Questions
**Is RUBS legal in Connecticut?**
No, not for residential tenants. The Connecticut Supreme Court held in Northland Investment Corp. v. PURA (2024) that ratio billing violates Conn. Gen. Stat. 16-262e(c). Public Act 26-113 makes a lease clause charging residents for utilities without a separate meter for their unit unenforceable, for leases signed or renewed on or after October 1, 2026.

**Does Public Act 26-113 apply to leases signed before October 1, 2026?**
The act itself applies to leases entered into or renewed on or after October 1, 2026. That doesn't make older leases safe. Northland already held in 2024 that ratio billing violates 16-262e(c), and that ruling does not depend on the lease date. Ask Connecticut counsel how to handle leases still running on an older form.

**Can a Connecticut landlord still charge tenants for water?**
Yes, two ways. Build an estimate of the water cost into a fixed rent, which the court said is allowed, or put a submeter on each unit and bill residents for what it measures, with PURA approval before the first bill.

**Does a submeter count as a separate meter under the new law?**
The act refers to a separate meter that measures utilities delivered only to the tenant's unit, and a submeter on that unit's water line does exactly that. It does not mention submeters by name, and no court has ruled on it yet. Some landlord groups asked that sewer fees require a utility company water meter for the unit, and the enacted text does not say that. PURA approval of the submeters is the step that ties the billing to state rules. Your counsel should confirm the lease language.

**Can I submeter electricity or gas in Connecticut?**
Gas, no. Electric only in the buildings Conn. Gen. Stat. 16-19ff lists: recreational campgrounds, marina boat slips, buildings whose power comes from Class I renewables or combined heat and power, and other locations PURA approves. Approved electric submetering must be billed at no more than the utility's own rate, and common-area use cannot be billed.

**How long does PURA take to approve submetering?**
For electric, PURA's instructions call for a completeness answer within 30 days of filing and aim for a decision within 60 days after the application is accepted as complete, though silence is never an approval. PURA publishes no deadline for water. File early, and expect resident notice and possible Consumer Counsel review along the way.

**Do Connecticut rental listings have to include utility charges?**
Under Public Act 25-44, in effect since October 1, 2025, advertised rent must include every fee or cost the tenant pays on a periodic basis, so utilities built into rent or charged as a flat monthly fee belong in the listed price. The act leaves out utilities submetered under 16-19ff (electric) and utilities the tenant pays straight to the utility company. It does not mention submetered water, so ask counsel how to list it.

**Converting a commercial building to apartments in Connecticut?**
Plan the metering at the design stage. Attorneys at Pullman & Comley wrote in June 2026 that Connecticut generally prohibits master metering in new multi-unit residential construction, with some exceptions, and that transformers and meters can take months to get. With RUBS off the table, each unit needs its own utility meter, a PURA-approved submeter, or utilities built into rent. NES can spec water submeters into the plumbing plans at the design stage, which avoids a retrofit later.

**Buying a Connecticut property that bills residents for utilities?**
Ask for the PURA docket number and decision for any submetering, and check the bills match what PURA approved. RUBS income on the seller's trailing 12 will fade as leases renew after October 1, 2026, so underwrite it that way. An electric approval does not transfer to a buyer, and counsel should confirm how a water approval moves with the sale.

**Does NES work in Connecticut?**
Yes. NES is a member of the Connecticut Apartment Association and submeters apartment communities across the state, including Hartford, New Haven, Stamford and Fairfield County. NES has done submetering and resident billing since 1968.